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partnership interest and the marketability discounts
determined by the experts and the minority discounts and
the combined discounts implied by the experts’
computations:
Petitioner’s Expert Respondent’s Expert
Net asset value of Hill House $10,332,769.00 $10,332,769.00
25.235-percent share 2,607,474.26 2,607,474.26
Minority discount percentage 42.6596 20.1344
FMV of the subject interest 1,495,136.00 2,082,474.00
before marketability discount
Marketability discount percentage 35.0015.00
FMV of the subject interest 971,838.00 1,770,103.00
Combined discount percentage 62.7287 32.1143
As shown above, the computations of petitioner’s expert
imply a combined discount of 62.7287 percent and the
computations of respondent’s expert imply a combined
discount of 32.1143 percent. We do not fully agree with
either expert. Set out below is our view of some of the
points about which the parties’ experts disagree and our
conclusion regarding the fair market value of the subject
limited partnership interest.
First, we agree with petitioner’s expert that it is
appropriate to consider the fair market value of the
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